9kup Privacy Policy

1. Introduction

1.1 This Privacy Policy applies to all users of the 9kup platform, accessible at https://9kup.app and any related subdomains or mobile-optimised interfaces operated by 9kup. It describes how 9kup collects, processes, stores, discloses, and protects personal data in connection with the provision of its online gaming services.

1.2 By registering a 9kup account, accessing the platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Privacy Policy, you must not use the 9kup platform.

1.3 This Privacy Policy should be read alongside the 9kup Terms & Conditions, which govern the overall relationship between you and 9kup. The Terms & Conditions are available at /terms-conditions.

1.4 9kup recognises its obligations under applicable data protection legislation and is committed to processing personal data fairly, lawfully, and transparently. We collect only the data necessary for legitimate operational and legal purposes and implement appropriate safeguards to protect the information we hold.

2. Data Controller

2.1 For the purposes of applicable data protection law, 9kup acts as the data controller in respect of personal data collected through the platform. As data controller, 9kup determines the purposes and means of processing your personal data.

2.2 Where 9kup engages third-party service providers to process personal data on its behalf (for example, payment processors, identity verification providers, and analytics services), those providers act as data processors and are contractually bound to process data only in accordance with 9kup's documented instructions and applicable data protection requirements.

2.3 If you have questions about how 9kup processes your personal data or wish to exercise any of your data subject rights, you may contact 9kup via the contact details set out in Section 15 of this Policy.

3. Data We Collect

3.1 9kup collects personal data in several ways — data you provide directly during registration and account use, data generated automatically through your interaction with the platform, and data obtained from third parties where permitted. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full name, date of birth, and gender;
• Email address and preferred username;
• Residential address (for identity verification purposes);
• Government-issued identification documents (e.g., MyKad, passport) where identity verification is required;
• Proof of address documentation (e.g., utility bills, bank statements).

3.2 Financial & Transaction Data

• Bank account details, e-wallet identifiers (e.g., Touch 'n Go, Boost, DuitNow), and FPX reference information associated with deposit and withdrawal transactions;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references;
• Wagering history including bet amounts, game selections, outcomes, and account balance movements;
• Source-of-funds documentation where required under applicable anti-money laundering obligations.

3.3 Technical & Usage Data

• IP address, device identifiers, browser type and version, operating system, and screen resolution;
• Session timestamps, pages visited, features accessed, and navigation paths within the platform;
• Geolocation data at the city or region level (e.g., Kuala Lumpur, Penang, Johor Bahru) derived from IP address;
• Cookie identifiers and similar tracking technologies as described in Section 7.

3.4 Communications Data

• Records of correspondence between you and 9kup's support team, including live chat transcripts, email content, and support ticket history;
• Voluntary feedback, survey responses, and account preferences where provided.

4. How We Use Your Data

4.1 9kup uses the personal data we collect for the following purposes:

• Account creation and management: To register your account, authenticate your identity at login, and maintain your account settings and preferences;
• Service delivery: To provide access to the 9kup sportsbook, live casino, slots, and other gaming products; to process deposits and withdrawals; and to settle wagers accurately;
• Identity verification and KYC compliance: To verify your identity and age (21+) at registration and as required by applicable anti-money laundering and know-your-customer regulations;
• Fraud prevention and security: To detect and prevent fraudulent activity, unauthorised account access, money laundering, and terms of service violations;
• Legal and regulatory compliance: To fulfil our obligations under applicable gaming regulations, anti-money laundering legislation, and any other legal requirements to which 9kup is subject;
• Responsible gaming enforcement: To monitor gaming behaviour, enforce deposit and loss limits, implement self-exclusion requests, and identify indicators of problem gambling;
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance;
• Platform improvement: To analyse usage patterns, diagnose technical issues, test new features, and improve the overall user experience on the 9kup platform;
• Communications: To send you account-related notifications, security alerts, transaction confirmations, and — where you have opted in — promotional communications.

4.2 9kup does not use automated decision-making processes (including profiling) that produce legal or similarly significant effects on users without human oversight, except where required to fulfil anti-money laundering or fraud detection obligations.

5. Legal Bases for Processing

5.1 Where applicable data protection law requires 9kup to identify a legal basis for processing personal data, we rely on the following bases:

• Contractual necessity: Processing necessary to perform the contract between you and 9kup — including account management, payment processing, and service delivery;
• Legal obligation: Processing necessary to comply with applicable laws and regulatory requirements, including anti-money laundering obligations, age verification requirements, and gaming licence conditions;
• Legitimate interests: Processing necessary for 9kup's legitimate interests, including fraud prevention, security, platform improvement, and responsible gaming monitoring, provided those interests are not overridden by your privacy rights;
• Consent: Where you have freely given specific consent, such as for the receipt of marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

6.1 9kup does not sell, rent, or trade your personal data to third parties for marketing purposes. We share personal data only in the following circumstances:

• Payment processors: Financial data is shared with payment service providers (including providers of Maybank2u, CIMB Clicks, Touch 'n Go eWallet, DuitNow, FPX, and Boost integrations) to the extent necessary to process your transactions;
• Identity verification providers: Identity and documentation data may be shared with third-party KYC and age verification service providers for the purpose of verifying your eligibility to hold a 9kup account;
• Game providers: Limited account and session data may be transmitted to 9kup's licensed game providers (e.g., Evolution Gaming, Pragmatic Play) to the extent necessary to deliver the game content you access;
• Regulatory authorities: 9kup may be legally obligated to disclose personal data to gaming regulatory authorities, financial intelligence units, law enforcement agencies, or courts where required by applicable law;
• Technology and analytics providers: Technical and usage data may be shared with infrastructure, hosting, and analytics providers who process data on 9kup's behalf under appropriate data processing agreements;
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of 9kup's business, personal data held by 9kup may be transferred to the relevant successor entity, subject to that entity assuming equivalent data protection obligations.

6.2 All third parties with whom 9kup shares personal data are contractually required to handle it in accordance with applicable data protection law and 9kup's data protection standards.

7. Cookies & Tracking Technologies

7.1 The 9kup platform uses cookies and similar tracking technologies to provide core functionality, improve the user experience, and gather aggregated usage analytics. The categories of cookies used include:

• Strictly necessary cookies: Essential for the platform to function correctly — including session authentication, security tokens, and load-balancing cookies. These cannot be disabled without impairing platform functionality;
• Functional cookies: Used to remember your preferences and settings between sessions (e.g., preferred language, account dashboard configuration);
• Analytics cookies: Used to collect aggregated and anonymised data about how users interact with the platform, enabling 9kup to identify improvement opportunities and diagnose performance issues;
• Security cookies: Used to detect anomalous access patterns, support fraud detection systems, and protect against cross-site request forgery attacks.

7.2 You may configure your browser to block or delete cookies; however, disabling strictly necessary cookies will prevent you from accessing core 9kup platform features, including logging in and placing wagers. Analytics and functional cookies may be disabled without material impact on core functionality.

7.3 9kup does not use cross-site tracking cookies for the purpose of serving third-party advertising or tracking your activity across unrelated websites.

8. Data Retention

8.1 9kup retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and contractual obligations. In practice:

• Account registration data and identity verification records are retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements;
• Financial transaction records and wagering history are retained for a minimum of five (5) years from the date of each transaction;
• Support communications are retained for two (2) years from the date of the most recent interaction, or longer where the communication is relevant to a pending dispute or legal proceeding;
• Technical and session data is retained for up to twelve (12) months from collection, or longer where required for security investigation purposes.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 9kup's data disposal procedures.

9. Security Measures

9.1 The security measures implemented by 9kup include, but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and the 9kup platform;
• Encryption at rest for sensitive personal data held in 9kup's data stores;
• Access controls restricting access to personal data to authorised 9kup personnel on a need-to-know basis;
• Session tokens that expire upon logout and are invalidated upon detection of anomalous activity;
• Regular security assessments and penetration testing of the 9kup platform and infrastructure;
• Incident response procedures for the timely detection, containment, and notification of personal data breaches.

9.2 Notwithstanding the foregoing, no method of data transmission or storage can be guaranteed to be completely secure. In the event of a material data breach affecting your personal data, 9kup will notify affected users and relevant authorities in accordance with applicable data breach notification obligations.

10. Your Data Rights

10.1 Subject to applicable data protection law and any overriding legal obligations (including anti-money laundering record-keeping requirements), you have the following rights in respect of your personal data held by 9kup:

• Right of access: You may request a copy of the personal data 9kup holds about you;
• Right to rectification: You may request that 9kup correct inaccurate or incomplete personal data held about you;
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to applicable retention obligations;
• Right to restriction: You may request that 9kup restrict the processing of your personal data in certain circumstances;
• Right to data portability: Where technically feasible and legally applicable, you may request a copy of personal data you have provided to 9kup in a structured, machine-readable format;
• Right to object: You may object to the processing of your personal data where 9kup relies on legitimate interests as the legal basis for processing;
• Right to withdraw consent: Where 9kup processes your data on the basis of your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

10.2 To exercise any of the above rights, please contact 9kup's support team via the contact details in Section 15. We will respond to verifiable requests within the timeframe required by applicable law, typically within 30 days of receipt. We may ask you to verify your identity before processing your request.

11. Children & Minors

11.1 The 9kup platform is not intended for use by persons under 21 years of age. 9kup implements age verification procedures at the point of registration to prevent underage access. If 9kup becomes aware that personal data has been collected from an individual under 21, that data will be deleted and the associated account closed immediately.

11.2 If you are a parent or guardian and believe that a minor has registered an account with 9kup, please contact our support team immediately so that the matter can be investigated and resolved promptly.

12. International Data Transfers

12.1 Where the performance of 9kup's services requires the transfer of personal data to recipients located outside of Malaysia (for example, game providers or infrastructure providers operating in other jurisdictions), 9kup takes steps to ensure that such transfers are made in compliance with applicable data protection law.

12.2 Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection, 9kup implements appropriate safeguards — such as standard contractual clauses or binding corporate rules — to protect your personal data in transit.

12.3 By using the 9kup platform, you acknowledge that your personal data may be processed in jurisdictions outside Malaysia where different data protection laws apply. 9kup will always ensure that your data is afforded appropriate protection regardless of where it is processed.

13. Third-Party Services & Links

13.1 The 9kup platform may contain references to third-party game providers whose software runs within the 9kup environment. Where you access game content delivered by a third-party provider, limited session and account data may be transmitted to that provider for the purpose of game delivery and fair-play auditing.

13.2 9kup does not operate third-party websites and is not responsible for the privacy practices of any third-party entity. This Privacy Policy applies exclusively to personal data processed by 9kup in connection with the 9kup platform at https://9kup.app.

13.3 All third-party providers that process personal data on behalf of 9kup are bound by data processing agreements that require them to process data only for the specified purpose, implement appropriate security measures, and promptly notify 9kup of any data breach affecting 9kup user data.

14. Policy Amendments

14.1 9kup reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, changes in our data processing practices, or operational developments. Material changes will be communicated to registered users via email notification or an in-platform notice prior to taking effect.

14.2 The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how 9kup protects your personal data.

14.3 Continued use of the 9kup platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised terms. If you object to any amendment, you should cease using the platform and may request the closure of your account.

15. Contact Us

15.1 For any questions, requests, or concerns relating to this Privacy Policy or 9kup's data processing practices, please contact our support team. 9kup's support team is available 24 hours a day, seven days a week via live chat on the platform.

15.2 Data subject rights requests — including requests for access, rectification, erasure, or portability — should be submitted with sufficient information to verify your identity. Please include your registered email address and a description of your request when making contact.